GE Spirit Letter R10822

8/4/2019 GE Spirit Letter R10822

1/64

Always with unyielding integrity

The Spirit& The Letter


2/64

1 STaTEmEnT o inTEGriTY

2 ThE SpiriT & ThE LETTEr:

GuidinG ThE WaY WE do buSinESS

3 GE codE o conducT

4 Your pErSonaL commiTmEnT

5 Who muST oLLoW GE

compLiancE poLiciES

6 WhaT EmpLoYEES muST do

7 WhaT LEadErS muST do

8 raiSE Your VoicE:

Your obLiGaTion To raiSE

inTEGriTY concErnS

9 hoW To raiSE an inTEGriTY concErn

10 WhaT happEnS WhEn an inTEGriTYconcErn iS raiSEd

11 pEnaLTiES or VioLaTionS

12 buSinESS poLiciES and procEdurES

13 ThE SpiriT & ThE LETTEr poLiciES

14 rEGuLaTorY ExcELLEncE

16 WorkinG WiTh cuSTomErS & SuppLiErS

18 Improper Payments20 Supplier Relationships24 International Trade Controls26 Money Laundering Prevention28 Privacy

30 GoVErnmEnT buSinESS

32Working with Governments

34 compETinG GLobaLLY

36 Complying with Competition Laws

38 in ThE GE communiTY

40 Fair Employment Practices44 Environment, Health & Saety46 Security & Crisis Management

48 proTEcTinG GE aSSETS

50 Intellectual Property52 Controllership56 Conlicts o Interest58 Insider Trading & Stock Tipping

60 indEx

61 appEndix: Which LaW appLiES

conTEnTS

This booklet is just an introduction to GE compliance policies.

The ull text o those policies and many other resources are

located at tegty.ge..


3/64

1

Statement o integrity

For more than 125 years, GE has demonstrated an unwaveringcommitment to perormance with integrity. At the same time wehave expanded into new businesses and new regions and builta great record o sustained growth, we have built a worldwidereputation or lawul and ethical conduct.

This reputation has never been stronger. In several surveys oCEOs, GE has been named the worlds most respected andadmired company. We have been ranked rst or integrity andgovernance.

But none o that matters i each o us does not make the rightdecisions and take the right actions. At a time when many peopleare more cynical than ever about business, GE must seek to earnthis high level o trust every day, employee by employee.

This is why I ask each person in the GE community to make apersonal commitment to ollow our Code o Conduct. This seto GE policies on key integrity issues guides us in upholding ourethical commitment. All GE employees must comply not only withthe letter o these policies, but also their spirit.

I you have a question or concern about what is proper conductor you or anyone else, promptly raise the issue with your manager,a GE ombudsperson or through one o the many other channelsthe Company makes available to you. Do not allow anything notmaking the numbers, competitive instincts or even a direct orderrom a superior to compromise your commitment to integrity.

GE leaders are also responsible not only or their own actions butor ostering a culture in which compliance with GE policy andapplicable law is at the core o business-specic activities. Leaders

must address employees concerns about appropriate conductpromptly and with care and respect.

There is no confict between excellent nancial perormance andhigh standards o governance and compliance in act, the twoare mutually reinorcing. As we ocus on becoming the pre-eminentgrowth company o the 21st century, we must recognize that onlyone kind o perormance will maintain our reputation, increase ourcustomers condence in us and our products and services, andenable us to continue to grow, and that is perormance with integrity.

Jerey R. ImmeltChairman o the Board & Chie Executive OcerJune 2005


4/64

2 The Spirit & The Letter

The Spirit & The Letter:guiding the way we dobusiness

Every day, everyone at GE has the power to infuence our companysreputation everywhere we do business. The Spirit & The Letter helps

to ensure that, ater more than 125 years, we still conduct our aairs

with unyielding integrity.

For well over a century, GE employees have worked hard to uphold

the highest standards o ethical business conduct. We seek to go

beyond simply obeying the law we embrace the spirit o integrity.

GEs Code o Conduct articulates that spirit by setting out general

principles o conduct everywhere, every day and by every GE employee.


5/64

GE code o conductObey the applicable laws and regulationsgoverning our business conduct worldwide.

Be honest, air and trustworthy in all your GE

activities and relationships.

Avoid all conficts o interest between work

and personal aairs.

Foster an atmosphere in which air employment

practices extend to every member o the diverseGE community.

Strive to create a sae workplace and to protect

the environment.

Through leadership at all levels, sustain a culture

where ethical conduct is recognized, valued andexemplied by all employees.


6/64


Your personalcommitmentYou will be asked to acknowledge your awareness that every

GE employee must ollow The Spirit & The Letter Policies and raise

concerns about possible violations o law or policy with a GEmanager, company legal counsel, GE auditor, GE ombudsperson

or other GE compliance specialist.

For the complete text o policies, visit the GE integrity Web site:

integrity.ge.com.


7/64

5

GE DIRECTORS, OFFICERS AND

EMPLOYEES

SUBSIDIARIES AND CONTROLLED

AFFILIATES Entities in which GEowns more than 50 percent othe voting rights, or has theright to control the entity, arerequired to adopt and ollowGE compliance policies.

NON-CONTROLLED AFFILIATESNon-controlled aliates shouldbe encouraged to adopt andollow GE compliance policies.

THIRD PARTIES REPRESENTING GEGE employees working with thirdparties, such as consultants,agents, sales representatives,

distributors and independentcontractors, must:

Require these parties to agreeto comply with relevantaspects o GEs compliancepolicies.

Provide these parties witheducation and inormationabout policy requirements.

Take action, up to and includ-

ing terminating a contract,ater learning that a thirdparty ailed to abide by GEscompliance policies.

Who must ollowGE compliance policies


8/64


UNDERSTAND GE POLICIES

Gain a basic understandingo the policy requirementssummarized in this booklet.

Learn the details o policiesrelevant to your job.

Check integrity.ge.com orthe complete and up-to-date

policies.Go to your manager, companylegal counsel or other GEresources with any questionsabout the policies.

RAISE YOUR CONCERNS

Promptly raise any concernsabout potential violations oany GE policy.

Understand the dierentchannels or raising integrityconcerns: ombudsperson,manager, GE lawyer, GE

auditor or other complianceresource.

I a concern you raise is notresolved, pursue the issue!Raise it through another oGEs channels.

Cooperate in GE investigationsrelated to integrity concerns.

What employees must doAll employees can contribute to GEs culture o compliance by

understanding GEs policies, embracing GEs commitment to integrity

and acting to enorce compliance and avoid violations.

Employee responsibilities are as ollows:


9/64

7

PREvENT COMPLIANCE ISSUES

Identiy business compliancerisks.

Ensure that processes, tailoredto address your particular riskareas, are communicated andimplemented.

Provide education on GEpolicies and applicable lawto employees and (whereappropriate) board membersand third parties.

Commit adequate resourcesto your businesss complianceprogram.

DETECT COMPLIANCE ISSUES

Implement control measures,such as dashboards andscorecards, to detect height-ened compliance risks and/orviolations.

Promote an eective ombuds-person system.

Ensure that periodic compli-ance reviews are conducted,with the assistance o businesscompliance leaders and/orthe Corporate Audit Sta.

RESPOND TO COMPLIANCE ISSUES

Take prompt corrective actionto x identied complianceweaknesses.

Take appropriate disciplinaryaction.

Consult with GE legal counseland make appropriate disclo-sures to regulators and lawenorcement authorities.

What leaders must doA leader must: create a culture o compliance in which employees

understand their responsibilities and eel comortable raising concerns

without ear o retaliation; encourage ethical conduct and compliance

with the law by personally leading compliance eorts; consider

compliance eorts when evaluating and rewarding employees; andensure that employees understand that business results are never

more important than ethical conduct and compliance with GE policies.

Leaders must also take the ollowing steps to build an inrastructure to

prevent, detect and respond to compliance issues:


10/64


Raise your voice:your obligation to raiseintegrity concerns

Raising an integrity concern protects the GE community:our company, our colleagues and our stakeholders.

I you have a concern about compliance with GE policy,

you have a responsibility to raise that concern.

RAISE CONCERNS EARLYThe longer we wait to addressa concern, the worse it maybecome.

YOU MAY REMAIN ANONYMOUSHowever, i you identiy yoursel,we are able to ollow up withyou and provide eedback.

CONFIDENTIALITY IS RESPECTEDYour identity and the inormationyou provide will be shared onlyon a need-to-know basis withthose responsible or resolvingthe concern.

RETALIATION vIOLATES GE POLICYGE absolutely prohibits retaliationagainst anyone or raising orhelping to address an integrityconcern. Retaliation is groundsor discipline up to and including

dismissal.

You can raise a concern orally or in writing.

I you preer, you can do it anonymously.


11/64

9

Speak up, ask questions, get answers. I your concern is not

addressed, raise it to one o the other channels.

How to raise anintegrity concernGE oers several channels or raising concerns. Use the channel

that is most comortable or you.

GE BOARD OF DIRECTORS

You may report concerns about GEs accounting, internal accounting controls or auditing matters,as well as other concerns, to the Board o Directors or the Audit Committee.

GE Board o DirectorsGeneral Electric Company (W2E)3135 Easton TurnpikeFaireld, CT 06828 U.S.A.

800-417-0575 (U.S.A. only)(1) [email protected]

WITHIN YOUR BUSINESS

Generally, your supervisor or manager will be in the best position to resolve an integrity concernquickly. However, your direct supervisor is not your only option. Other resources include:

Your compliance leader orauditor

Company legal counsel

Next level o management

Your business ombudspersonor integrity helpline (listed atintegrity.ge.com)

GE CORPORATE OMBUDSPERSON

The GE Ombudsperson process allows you to voice your integrity questions and concerns,anonymously i you choose, and you will receive a response.

P.O. Box 911Faireld, CT 06430U.S.A.

800-227-5003 (U.S.A. only) or8*229-2603 or (1) [email protected]


12/64


What happenswhen an integrityconcern is raised

Concerns about compliance with GE policy will be investigated.GEs investigation process includes:

1. ASSIGNING AN INvESTIGATION TEAMExperts with the right knowledge and objectivityare assigned to investigate.

2. CONDUCTING AN INvESTIGATIONThe team determines the acts through interviews

and/or review o documents.3. CORRECTIvE ACTION

I necessary, the team recommends corrective actionsto the appropriate managers or implementation.

4. FEEDBACKThe person raising the concern receives eedbackon the outcome.


13/64

11

Violating GE policy.

Requesting others to violateGE policy.

Failure to promptly raise aknown or suspected violationo GE policy.

Failure to cooperate in GEinvestigations o possiblepolicy violations.

Retaliation against anotheremployee or reporting anintegrity concern.

Failure to demonstrateleadership and diligence toensure compliance with GE

policies and law.

Penalties or violationsEmployees and leaders who violate the spirit orletter o GEs policies are subject to disciplinaryaction up to and including termination o

employment. Misconduct that may result indiscipline includes:

GE absolutelyprohibits retaliation


14/64


Business policiesand proceduresYour business may issue its own policies and procedures.

You must ollow those policies and procedures in addition to

those described in this guide.

IMPORTANT This guide and the policies described in it are not an

employment contract. GE does not create any contractual rights

by issuing this guide or the policies.


15/64

The Spirit

& The Letterpolicies

Introduction: Regulatory excellenceWorking with customers & suppliers

Government businessCompeting globally

In the GE community

Protecting GE assets


16/64


Regulatory excellenceVirtually all o our Spirit & Letterpolicies are based ongovernment laws and regulations. These regulationsimpact every GE business and every GE employee.

Regulators establish and dene the rules that wemust comply with to conduct business. Eectivelyengaging with regulators as they establishregulations and assuring compliance with theseregulations are critical to maintaining GEsreputation or integrity.

Todays regulatory environment is becoming moreand more challenging. GE is subject to a growingnumber o regulations and enorcement activitiesaround the world. This environment demands that

every employee and leader be aware, knowledgeableand committed to regulatory excellence.


17/64

15

RESPONSIBILITIES OF ALL EMPLOYEES

Be knowledgeable about and comply withthe Spirit & Letterpolicies that aect your jobresponsibilities.

Be aware o the specic regulatory requirementso the country and region where you work andthat aect your business.

Gain a basic understanding o the keyregulators (who they are) and the regulatorypriorities (what they require) that aect your

business and your work.

Promptly report any red fags or potentialissues that may lead to a regulatorycompliance breach.

Always treat regulators proessionally, withcourtesy and respect.

Assure that you coordinate with businessor corporate experts when working with or

responding to requests o regulators.

RESPONSIBILITIES OF ALL LEADERS

Leaders have the ollowing special responsibilitiesor regulatory compliance:

LEAD

Assure that you and your team are engaged inaddressing regulatory policy, meeting regulatoryrequirements and managing regulatory risks.

Embed regulatory requirements into keyoperating processes. (e.g., Growth Playbook,Session C and Session D)

ASSESS

Determine the key regulators and regulatoryrequirements that aect your businessoperations globally.

RESOURCE

Assign owners or all regulatory risk areas andassure that they coordinate with any relevantgovernment relations and corporate regulatoryspecialists.

Conrm that the right domain expertise existsto eectively manage regulatory relationshipsand compliance.

ANTICIPATE

Implement eective processes that alert you tonew and changing regulations. Include regulationin your risk assessments.

RELATE

Develop and maintain eective relationships with

regulators in coordination with governmentrelations and compliance experts.

Work proactively with regulators on thedevelopment o regulations that achieve policyobjectives eciently and eectively.

CONTROL

Monitor execution and conduct audits toassure that processes which support regulatoryrelationships and compliance are operatingeectively.


18/64

Working with

customers &suppliers

Section One Improper paymentsSupplier relationships

International trade controlsMoney laundering prevention

Privacy


19/64

17

Workingwith

customers&suppliers

Your low-cost supplier oersgood quality and reliable delivery

at prices that cant be beat.But you are uncomortable with

the working and living conditionsit provides its workers.

Shrug it o, or makean issue o it?

SEE PAGE 20:

SUPPLIER RELATIONSHIPS

An overseas customer has been invitedto travel to visit our training acility at GEexpense, but also wants to add a weekend

side trip to visit Universal Studios.

Can we und the whole trip?

SEE PAGE 18:

IMPROPER PAYMENTS


20/64


Improper paymentsWHAT TO KNOW

An improper payment to gain advantage in anysituation is never acceptable and exposes you and

GE to possible criminal prosecution. GE expresslyprohibits improper payments in all businessdealings, in every country around the world, withboth governments and the private sector.

Improper payments should not be conused with

reasonable and limited expenditures or gits,business entertainment and customer travel andliving expenses directly related to the promotion oproducts or services or the execution o a contract.These payments are acceptable, subject to specic

GE corporate and business guidelines.

ANSWER TO QUESTION ON PAGE 17 It depends on many actors, including whether your customer is agovernment ocial, the local law, the customers policies, your businesss guidelines and other acts.You must consult with GE counsel and your manager to determine whether the trip is acceptable.


21/64

19

Workingwith

customers&suppliers

for more in-depth information go to: integrity.ge.com

BEFORE GIvING A GIFT, engagingin customer entertainment orreimbursing customer travelexpenses, make sure you under-stand applicable legal require-ments, the customers own rulesand GE corporate and businessguidelines.

MAKE SURE RECORDS OF SUCH

ExPENDITURES accurately refectthe true nature o the transaction.

NEvER OFFER A BUSINESS COURTESY,such as a git, contribution orentertainment, under circum-stances that might create theappearance o an impropriety.

NEvER OFFER, PROMISE, PAY OR

AUTHORIzE anything o value

(such as money, goods or ser-vices) to a government ocialor employee o a customer toobtain or retain an improperadvantage.

NEvER GIvE A GRATUITY or otherpayment to government ocialsor employees to expedite aroutine administrative actionwithout ully disclosing it to theGE National Executive or GElegal counsel. Some nationallaws that prohibit bribery outsidethat nation include an exceptionor acilitating payments to

expedite a routine administra-tive action to which a person isotherwise entitled. These pay-ments are oten illegal underlocal anti-bribery laws, and GEstrongly discourages them. Makesure you understand the dier-ence between a bribe corruptlygiving someone else a thing ovalue in exchange or exercisingdiscretion in your avor anda acilitating payment, whichinvolves the payment o a smallamount o money to expedite aroutine action to which you areentitled.

NEvER CONTRIBUTE COMPANY

FUNDS or other company assetsor political purposes in theUnited States without the priorapproval o GEs Vice Presidentor Government Relations. Nevercontribute company unds orother company assets or politi-cal purposes outside the UnitedStates without the approval o

both GEs Vice President orGovernment Relations and GEsVice President or InternationalLaw and Policy.

REQUIRE ANY PERSON OR FIRM

WHO REPRESENTS GE (such as aconsultant, agent, sales repre-sentative, distributor or contrac-tor) to comply with this policyand related laws.

FOLLOW YOUR BUSINESSS DUE

DILIGENCE PROCEDURES whenselecting persons or rms torepresent GE.

WHAT TO DO

WHAT TO WATCH OUT FOR

BACKGROUND INFORMATION aboutexisting or potential third-partyrepresentatives that indicates:

Allegations o improperbusiness practices.

Reputation or bribes.

Family or other relationshipthat could improperly infuencethe decision o a customer orgovernment ocial.

ANY DEMAND to receive acommission payment beorethe announcement o anaward decision.

ANY SUGGESTION TO DIRECT GE

BUSINESS through a specicrepresentative or partner dueto a special relationship.

ANY REQUEST to make a paymentin a country or to a name notrelated to the transaction.

A COMMISSION that is dispropor-tionate to the services provided.


22/64


Supplier relationshipsWHAT TO KNOW

GEs relationships with suppliers are based onlawul, ecient and air practices. We expect our

suppliers to obey the laws that require them totreat workers airly, provide a sae and healthywork environment and protect environmentalquality. Following GE guidelines helps ensure thatour supplier relationships will not damage GEsreputation.

ANSWER TO QUESTION ON PAGE 17 Dont shrug it o. Its a big issue GEs reputation dependson doing business only with suppliers that deal responsibly with their workers and with theirlocal environments.


23/64

21

Workingwith

customers&suppliers


COMPLY WITH APPLICABLE LAWSand government regulationscovering supplier relationships.

DO BUSINESS only with suppliersthat comply with local and otherapplicable legal requirementsand GE guidelines relating tolabor, the environment, healthand saety. Follow the proce-

dures set out in GEs SupplierReputational Guidelines, oundat integrity.ge.com.

FOLLOW GOvERNMENT ACQUISITION

REGULATIONS when purchasingmaterials and services or ulll-ing government contracts.

PROvIDE A COMPETITIvE OPPOR-

TUNITY or suppliers to earn ashare o GEs purchasing volume,including small businessesand businesses owned by the

disadvantaged, minorities,women and disabled veterans.

SAFEGUARD GES CONFIDENTIAL

AND PROPRIETARY INFORMATIONwith a condentiality agreement,and saeguard any supplier-provided inormation protectedby any condentiality agreement.

SAFEGUARD PERSONAL DATAobtained rom suppliers(or instructions, see Privacy

on page 28).

WHAT TO DO

CHOOSING SUPPLIERS on any basisother than open, competitivebidding.

POTENTIAL CONFLICTS OF INTERESTin supplier selection, such asaccepting improper gits orother items o value.

DIRECTING BUSINESS TO A SUPPLIERowned or managed by a relativeor close riend.

UNSAFE CONDITIONS in supplieracilities.

SUPPLIER EMPLOYEES who appear

to be underage or subject tocoercion.

APPARENT DISREGARD o environ-mental standards in supplieracilities.

ENTRUSTING PERSONAL DATA orcondential inormation tosuppliers without ensuring thatthey have appropriate technical,

physical, and organizationalmeasures to prevent unauthor-ized access or use.



24/64


You seek lower-cost suppliers in key

areas and have ound a non-domesticsupplier that looks promising.

Can you e-mail technical drawingsto see i this new company has thecapabilities you need?

SEE PAGE 24:

INTERNATIONAL TRADE CONTROLS

A representative rom a potentialnew customer or supplier has givenyou his card, containing his nameand contact details.

Is it OK to put this inormation in adatabase where other GE personnelcan access it?

SEE PAGE 28:

PRIvACY


25/64

23

Workingwith

customers&suppliers

A longtime GE customer recently opened

a new import/export company in Nevada.Her company wants to purchase medicalequipment or a private clinic in the MiddleEast. She oers to pay via a wire transerrom an account held in the name o aBritish Virgin Islands company at a banklocated in a Pacic island nation.

Should I be suspicious?

SEE PAGE 26:MONEY LAUNDERING PREvENTION


26/64


International TradeControlsWHAT TO KNOW

International Trade Control (ITC) laws aect the

transmission o goods, services and technologyacross national borders. These laws apply to manyaspects o GEs operations not just shippingproducts. Exchanges o inormation across nationalboundaries, including e-mail and web access,

are subject to trade controls. The United Statesalso controls the release o technical inormationto non-U.S. nationals within the United States.It is important that we careully observe ITC lawsin connection with these activities.

ANSWER TO QUESTION ON PAGE 22 It depends on the export classication o the technicalinormation and your businesss Know Your Supplier policy check with your businesssITC expert or specic guidance.


27/64

25

Workingwith

customers&suppliers


FOLLOW RELEvANT ITC REGULATIONSo all countries in which youoperate and your businesss ownITC procedures as they relate toimporting and exporting goods,technology, sotware, servicesand nancial transactions.

REPORT ALL RELEvANT INFORMATIONto your import manager to

ensure accurate and completeimport declarations. Ensure GEor its agent provides accurateand complete inormation togovernment authorities.

CHECK THE ExPORT CLASSIFICATIONo the product, sotware ortechnology prior to export todetermine whether specialauthorization is required.

SCREEN YOUR TRANSACTIONSagainst all applicable rules thatrestrict transactions with certainsanctioned countries, persons

and prohibited end uses.

SCREEN ALL YOUR BUSINESS

PARTNERS, suppliers and partiesinvolved in your internationaltransactions against government-provided watch-lists. Follow yourbusinesss Know Your Customer/Know Your Supplier procedures.

DO NOT COOPERATE WITH ANY

RESTRICTIvE TRADE PRACTICE orboycott that is prohibited orpenalized under U.S. or appli-cable local laws.

CONSULT WITH YOUR MANAGER i atransaction involves a confictbetween U.S. law and applicablelocal laws, such as the laws

adopted by Canada, Mexico andthe members o the EuropeanUnion blocking certain U.S.restrictions.

ANY FACTS, SOMETIMES KNOWN AS

RED FLAGS, that suggest yourcustomer may be attempting toevade ITC laws (a complete listo Red Flags is available romthe International Law & Policysite ound at integrity.ge.com).

EvASIvE, RELUCTANT OR OTHERWISE

UNSATISFACTORY ANSWERS by acustomer to questions aboutend use, end user, deliverydates or delivery locations.

INvOLvEMENT OF PARTIES OR

ACTIvITIES suspected o anyconnection with the develop-ment o biological, chemical ornuclear weapons, or ballisticmissiles.

TRANSACTIONS INvOLvING AN

EMBARGOED COUNTRY, a citizen orrepresentative o an embargoedcountry or an individual or entitysubject to government sanction.

INvOICES ON IMPORTED GOODSwhere the price shown doesnot refect the ull value, the

description o the goods is notcomplete, or the country oorigin is not correctly identied.

ANY PAYMENT TO THE ExPORTER orbeneting the exporter that isnot included in the invoice priceor otherwise reported.

TRANSFER PRICES between relatedparties that ail to cover appro-

priate costs and prots.

USE OF AN IMPORT TARIFF

CLASSIFICATION that does notseem to describe the importedgoods accurately.

DESIGNATION OF GE AS THE

IMPORTER OF RECORD (partyresponsible or an importation)without maintaining necessary

processes to comply withimport laws.

ENTRY OF GOODS UNDER A PREFER-

ENTIAL DUTY PROGRAM (GSP, NAFTA,

ETC.) without supportive proce-dures assuring compliance withthe programs requirements.

WHAT TO DO



28/64


Money launderingpreventionWHAT TO KNOW

People involved in criminal activity e.g., terrorism, narcotics, bribery,

and raud may try to launder the proceeds o their crimes tohide them or make them appear legitimate. More than 100 countries

now have laws against money laundering, which prohibit conducting

transactions that involve proceeds o criminal activities. A related

concern is that legitimate unds may be used to nance terrorist

activity sometimes called reverse money laundering.

GE is committed to complying ully with all anti-money laundering andanti-terrorism laws throughout the world. GE will conduct business

only with reputable customers involved in legitimate business activities,

with unds derived rom legitimate sources. Each GE business is

required to implement risk-based Know Your Customer due diligence

procedures calibrated to the risk in question, and to take reasonable

steps to prevent and detect unacceptable and suspicious orms o

payment. Failing to detect customer relationships and transactions that

place GE at risk can severely damage GEs integrity and reputation.

ANSWER TO QUESTION ON PAGE 23 Yes, you should be suspicious i a transaction involves transerringunds to or rom countries or entities unrelated to the transaction or not logical or the customer.Moreover, requests to transer money to third parties also raise red fags that need to be investigatedto ensure the legitimacy o the transaction. Consult with company counsel or a GE anti-moneylaundering specialist beore proceeding.


29/64

27

Workingwith

customers&suppliers


COMPLY WITH ALL APPLICABLE LAWSand regulations that prohibitmoney laundering and supportand nancing o terrorism, andthat require the reporting ocash or suspicious transactions.Understand how these lawsapply to your business.

FOLLOW YOUR BUSINESSS KNOW

YOUR CUSTOMER PROCEDURES.Collect and understand docu-mentation about prospectivecustomers, agents and business

partners to ensure that they areinvolved in legitimate businessactivities and their unds comerom legitimate sources.

FOLLOW YOUR BUSINESSS RULESconcerning acceptable orms opayment. Learn the types opayments that have becomeassociated with money launder-

ing (or example, multiple moneyorders or travelers checks, orchecks on behal o a customerrom an unknown third party).

IF YOU ENCOUNTER A WARNING

SIGN o suspicious activity, raiseyour concern with a designatedGE anti-money laundering com-pliance specialist or companylegal counsel and be sure toresolve your concern promptlybeore proceeding urther withthe transaction. Ensure the res-olution is well documented.

WHAT TO DO

A CUSTOMER, AGENT OR PROPOSED

BUSINESS PARTNER who is reluc-tant to provide complete inor-

mation, provides insucient,alse or suspicious inormation,or is anxious to avoid reportingor record keeping requirements.

PAYMENTS using monetary instru-ments that appear to have noidentiable link to the customer,or have been identied asmoney laundering mechanisms.

ATTEMPTS BY A CUSTOMER orproposed business partner topay in cash.

EARLY REPAYMENT o a loan incash or cash equivalents.

ORDERS, PURCHASES OR PAYMENTSthat are unusual or inconsistentwith the customers trade or

business.

UNUSUALLY COMPLEx DEAL

STRUCTURES, payment patternsthat refect no real businesspurpose, or unusually avorablepayment terms.

UNUSUAL FUND TRANSFERS to orrom countries unrelated to thetransaction or not logical or

the customer.

TRANSACTIONS INvOLvING

LOCATIONS identied as secrecyhavens or areas o known terror-ist activity, narcotics trackingor money laundering activity.

TRANSACTIONS INvOLvING FOREIGN

SHELL OR OFFSHORE BANKS,unlicensed money remitters or

currency exchangers, or non-bank nancial intermediaries.

STRUCTURING OF TRANSACTIONS TO

EvADE RECORD KEEPING or report-ing requirements (or example,multiple transactions below thereportable threshold amounts).

REQUESTS TO TRANSFER MONEY orreturn deposits to a third party

or unknown or unrecognizedaccount.



30/64


PrivacyWHAT TO KNOW

A growing number o countries are morestringently regulating the collection and use o

consumers personal data (names, home andoce contact inormation, and other data).In addition, many countries regulate personaldata o company representatives in business-to-business transactions. A ew countries evenregulate the privacy o inormation relating tocorporations. GE is committed to handlingpersonal data responsibly and in compliancewith applicable privacy laws.

ANSWER TO QUESTION ON PAGE 22 I you collected this data in a country regulated by a personal dataprotection law or example, most countries in Europe you may be prohibited by law rom usingor sharing the inormation where the person to whom the data pertains has not granted expressconsent. I you are not sure, consult with the Chie Privacy Leader or your business listed on thePrivacy site at Support Central.


31/64

29

Workingwith

customers&suppliers


INADEQUATE ACCESS OR SECURITYCONTROLS or personal data,such as e-mailing or otherwisedistributing personal data to alarger group than legitimatelyneeded, or leaving printoutswith personal data at a printer,copy machine or ax machineor others to see.

SHARING OF PERSONAL DATA withunaliated third parties, suchas vendors or suppliers, wholack appropriate security sae-guards or restrictions on inor-mation use.

TRANSFERS OF PERSONAL DATAbetween countries, withoutconsidering applicable legalrequirements.


LEARN AND COMPLY with theollowing as they apply topersonal data including:

Applicable laws and regula-tions o jurisdictions romwhich the personal data iscollected and in which it isprocessed or used.

The privacy policies o GE andyour business.

Any contractual obligationsthat apply.

COLLECT, PROCESS AND USE

PERSONAL DATA or legitimatebusiness purposes only.

USE ANONYMOUS DATA (namesremoved and not identiable) oraggregated data (summarizedso as not to be identiable to anindividual) instead o personaldata where appropriate orrequired.

LIMIT ACCESS to personal data toindividuals who need it or a

legitimate business purpose.

USE CARE to prevent unauthor-ized access in processing opersonal data or accidental lossor destruction o personal data.

IF YOU LEARN THAT PERSONAL DATA

HAS BEEN USED IN vIOLATION othis policy or your businesssprivacy implementing proce-dures, or i you learn that thesecurity o any system or devicecontaining personal data hasbeen compromised, immediatelynotiy your manager, businessPrivacy Leader or company

legal counsel.

WHAT TO DO


32/64

Governmentbusiness

Section Two Working with governments


33/64

31

Governmentbusiness

We are entitled to a large payment roma government customer i we certiy thatproject installation has been completed.Were not sure whether a ew small itemshave been installed yet, but they shouldbe soon. Its getting close to year-end,and wed like to book the payment.

Can we submit our inoice andcertication now?

SEE PAGE 32:

WORKING WITH GOvERNMENTS


34/64


Working withgovernmentsWHAT TO KNOW

GE conducts business with national governments

and government-owned enterprises. In the courseo our work, we requently interact with governmentagencies, ocials and public international agencies.In every instance, GE employees must apply thehighest ethical standards and comply with

applicable laws and regulations, including certainspecial requirements associated with governmenttransactions.

ANSWER TO QUESTION ON PAGE 31 No, you cannot submit the invoice and certication until you arecertain that the entire installation has been completed in accordance with the contract. Submissiono an incorrect certication could subject the company, and you personally, to criminal penalties.Thereore, it is extremely important that all certications submitted to the government be current,accurate and complete.


35/64

33

Governmentbusiness

for more in-depth information go to: gr.g.

Abide by ApplicAble lAws and

regulations relating to working

with governments, particularly

special requirements associated

with government contracts and

transactions.

RequiRe anyone providing goods

or services or GE on a govern-

ment project or contract such

as consultants, sales representa-tives, distributors or suppliers

to agree to comply with the

intent o GEs Working with

Governments policy.

be tRuthful And AccuRAte

when dealing with government

ocials and agencies.

Adopt pRocesses thAt ensuRe

reports, certications, state-

ments and proposals are current,

accurate and complete and

that contract requirements are

adequately identied and com-

municated to the responsibleparties.

do not mAke Any unAuthoRized

substitutions or contracted

goods and services or deviate

rom contract requirements

without the written approval

o the authorized government

ocial.

whAt to do

speciAl RequiRements that apply

to transactions with govern-

ments, including commercialtransactions between private

parties nanced by government

agencies such as the EX-IM Bank,

U.S. Agency or International

Development, the European

Union or the European Bank

or Reconstruction and

Development.

incoRRect oR unAuthoRized

cost-chARGinG on governmentcontracts.

deviAtions fRom contRAct

RequiRements or unauthorized

contract substitutions, such as

ailure to perorm required tests

and inspections.

submission of inAccuRAte oR

incomplete cost or pricing data

when this data is required bythe government.

violAtinG GoveRnment ReGulA-

tions that establish gratuity

restrictions, recruiting and hiringrestrictions, or certication

procedures.

AcceptinG infoRmAtion about

a governments competitive

selection o a supplier, or a

competitors bid or proposal

(unless the contracting ocer or

agency leader has specically

and lawully authorized the

inormations release).

neGotiAtinG foR employment

with a government ocial or

government ocials amily

members while the ocial has

the ability to infuence decision-

making about contracts with

the government.

violAtions of the u.s.

GoveRnment zeRo toleRAnce

policy regarding tracking inpersons. This anti-tracking

policy is applicable to employ-

ees directly engaged in peror-

mance o work on all U.S.

Federal Government contracts.

Employees that violate this policy

may be subject to disciplinary

action up to and including ter-

mination, and may subject the

company to contract termina-

tion, suspension or debarment.Our Companys Working

with Governments Policy at

gr.g. provides

additional details.

whAt to wAtch out foR


36/64

Competingglobally

Section Three Complying with competition laws


37/64

35

Competingglobally

There is a big account I think mybusiness could land but only i wepartner with one o our competitorsto go ater it .

Can we work together withoutiolating the competition laws, orshould I let this opportunity pass?

SEE PAGE 36:

COMPLYING WITH COMPETITION LAWS


38/64


Complying withcompetition lawsWHAT TO KNOW

Competition and antitrust laws:

Prohibit agreements or understandings between competitors

that undermine competition;

Regulate the behavior o dominant companies; and

Require prior review and in some instances clearance or mergers,

acquisitions and certain other transactions, in order to prevent

transactions that would substantially reduce competition.

These laws are complex, and global in reach, and can operate

dierently in any particular situation. Your business provides specic

guidelines on addressing contacts with competitors, obtaining

and handling data about competitors, and participating in trade

and proessional associations and standards setting and product

certication organizations. In addition, it is oten essential thatyou involve legal counsel early in the process o developing new

commercial initiatives given the many uncertainties that arise in the

application o these laws.

ANSWER TO QUESTION ON PAGE 35 Partnering with a competitor or a specic project may be permissiblewhen the result is an improvement in the solution oered to the customer; or example, when bothcompanies together can provide an oering that neither would be able to supply separately. Alwaysseek legal advice beore agreeing to work with a competitor on a joint proposal.


39/64

37

Competingglobally


COMPLY with all applicable com-petition laws and regulations aswell as competition law decrees,orders and agreements with anycompetition regulator abouthow business will be conducted.

REvIEW AND UNDERSTAND both GEand business-specic policiesand procedures, and i you have

questions or issues, bring themup with company legal counsel.

DO NOT propose or enter intoagreements or understandings expressed or implied, ormal orinormal, written or oral withany competitor regarding anyaspect o the competitionbetween GE and the competitor.Do not discuss with a competitor

or competitor representative:Prices

Bids

Sales territories, allocation ocustomers or product lines

Terms or conditions o sale

Production, sales capacityor volume

Costs, prots or prot margins

Market share

Product or service oerings

Customer or supplierclassication

Distribution methods

DO NOT propose or enter intoagreements with anyone (includ-ing competitors, agents, brokersor customers) regarding whetherto submit a bid or the terms oa bid where there is an under-standing that the bid is submit-ted or any purpose other thanwinning the business.

AvOID CONTACTS o any kind withcompetitors that could createthe appearance o improperagreements or understandings.

DO NOT propose or enter intoagreements or understandingswith customers that restrict theprice or other terms at whichthe customer may resell orlease a product or service to athird party.

DO NOT propose or enter intoagreements or understandings

with suppliers that restrict theprice or other terms at whichGE may resell or lease anyproduct or service.

CONSULT with company legalcounsel to help reduce the riskso noncompliance in the evalu-ation o any proposed merger,acquisition, joint venture or anyother business arrangement

that could raise competition lawissues (examples o arrange-ments that need to be discussedwith counsel are listed in Whatto Watch Out For below).

WHAT TO DO

ExCLUSIvE ARRANGEMENTS or thepurchase or sale o products orservices.

BUNDLING o goods and services.

AGREEMENTS THAT RESTRICT A

CUSTOMERS CHOICES in using orreselling a GE product or service.

TECHNOLOGY LICENSING agree-ments that restrict the reedomo the licensee or licensor.

SELECTIvE PRICE DISCOUNTING toonly certain customers.

DISTRIBUTION ARRANGEMENTS withcompetitors.

AGREEMENTS TO ADD A GEEMPLOYEE to another entitysboard o directors.



40/64

In the GEcommunity

Section Four Fair employment practicesEnvironment, health & saety

Security & crisis management


41/64

39

IntheGEcommunity

Im disabled and required to attend anosite meeting that is not physicallyaccessible or me.

Dont I hae rights osite?

SEE PAGE 40:

FAIR EMPLOYMENT PRACTICES


42/64


Fair employmentpracticesWHAT TO KNOW

Fair employment practices do more than keep

GE in compliance with applicable labor andemployment laws. They contribute to a cultureo respect. GE is committed to complying withall laws pertaining to reedom o association,privacy, collective bargaining, immigration,

working time, wages and hours, as well as lawsprohibiting orced, compulsory and child laborand employment discrimination. Beyond legalcompliance, we strive to create an environmentconsiderate o all employees wherever GE

business is being conducted.

ANSWER TO QUESTION ON PAGE 39 Yes. Reasonable accommodations should be made to provide accessand acilitate ull participation in the meeting, or alternative arrangements should be made or you.


43/64

41

IntheGEcommunity


BASE EMPLOYMENT DECISIONS onjob qualications (e.g., educa-tion, prior experience) and merit.Merit includes an individualsskills, perormance, values, lead-ership and other job-relatedcriteria.

MAKE ALL EMPLOYMENT RELATED

DECISIONS AND ACTIONS without

regard to a persons race, color,religion, national origin, sex(including pregnancy), sexualorientation, age, disability,veteran status or other charac-teristic protected by law.

PROvIDE A WORK ENvIRONMENTree o improper harassmentand bullying.

RESPECT THE PRIvACY RIGHTS oemployees by using, maintain-ing and transerring personaldata in accordance with GEsEmployment Data ProtectionStandards and related procedures

ound at integrity.ge.com. (Whileseeking to maintain employeeprivacy, GE reserves the rightto monitor use o companyproperty, including computers,e-mail, phones, proprietaryinormation, etc., in accordancewith applicable law.)

TAKE LAWFUL AFFIRMATIvE ACTIONSin the United States, and else-where i required by local law,to increase opportunities inemployment or women, minori-ties, people with disabilities andcertain veterans.

IF A CONFLICT ARISES betweenthe requirements o this policy

and the laws, customs orpractices o a particular area,consult with managementand company legal counsel todetermine the most appropriatecourse o action.

WHAT TO DO

A HOSTILE WORK ENvIRONMENT(or example, telling jokes ordisplaying materials that ridiculeor oend a member o a particu-lar race or ethnic group).

MAKING UNWELCOME SExUAL

ADvANCES to another employeeor person with whom you work.

vIOLATING A LABOR LAW in yourcountry (or example, hiring achild under the legal minimumage).

REFUSING TO WORK, or otherwisecooperate with, certain individu-als because o their race, religion,sex, or other characteristic pro-tected by law.

DISCLOSING EMPLOYMENT DATAto a person who does not havethe business need, authority orthe subjects consent.

TAKING AN ADvERSE ACTIONagainst an employee (e.g., ring)because the employee hasraised a concern about a viola-tion o policy or law.



44/64



45/64

43

IntheGEcommunity

A new customer wants to place a bigorder with GE, provided the equipment

can be shipped to them overnight.That doesnt give us enough time to do

the required Watchlist screening.

Can I ship the equipment today andcheck the Watchlists tomorrow?

SEE PAGE 46:

SECURITY & CRISIS MANAGEMENT

Youre dispatched to rewire a customersailing electrical system. Unortunately,the customer cannot completely shutdown the system or repairs as planned.

You accomplish most o the job byshutting down parts o the system asneeded. Finally, all that remains is somesimple rewiring that requires a moredisruptive shut-down. The customer asksyou, as a avor, to do this work with noshut-down. You eel condent that youcan do it with minimal risk.

Can you do the customer this aor?SEE PAGE 44:

ENvIRONMENT, HEALTH & SAFETY


46/64


Environment,health & saetyWHAT TO KNOW

Protecting the environment and the health and

saety o employees is the law and GE believesits also the right thing to do. Through managementleadership and employee commitment, GE worksto conduct its operations in a sae manner thatminimizes environmental impact. This policy

aects all company activities not just managingour waste and emissions, but everything we do or example, selling products, driving a car oncompany business, acquiring a new business orproviding customer service.

ANSWER TO QUESTION ON PAGE 43 Absolutely not. Both GE policy and sae work practices require thatenergized machinery be de-energized beore work is commenced.


47/64

45

IntheGEcommunity


COMPLY with all applicable envi-ronmental health and saety(EHS) laws and regulations,and GE EHS policies.

CREATE AND MAINTAIN a saeworking environment and pre-vent workplace injuries.

ASSESS EHS LEGAL AND REPUTA-

TIONAL RISKS beore starting anew activity, venture or project,selling a new product, acquiringa new business or participatingin a hazardous business.

CONSIDER EHS IMPACTS in thedesign and production o GEsproducts and services as parto evaluating the lie cycle oour products.

ELIMINATE UNREASONABLE EHS

RISKS rom GEs acilities, prod-ucts, services and activities.

AS PRACTICABLE, REDUCE TOxICAND HAzARDOUS MATERIALS; pre-vent pollution; and conserve,recover and recycle materials,water and energy.

CONTINUE TO IMPROvE OUR EHS

SYSTEMS and perormance as anintegral part o GEs operationalstrategy.

PRESENT IDEAS that support thegoals o this policy to yourmanager or your businesssEHS manager.

PROMPTLY ALERT YOUR MANAGERor EHS contact o unlawul orunsae conditions.

WHAT TO DO

UNSAFE ACTIvITIES AND CONDITIONS,such as:

Failure to use personal protec-tive equipment (shoes, saetyglasses, hearing protection,gloves, monitors, etc.).

Unlabeled or unapprovedchemicals.

Exposed or unsae wiring.

Blocked re or emergencyexits.

Unsae driving, or ailure towear seat belts or ollow GEsdriving policies.

Working in high places with-out all protection.

Working beneath heavy, sus-pended loads, or improperlyusing cranes.

Working on electrical orpowered equipment without

ollowing saety (e.g. lock-out,tag-out) procedures.

Working unsaely at acustomer site.

Potential exposure to seriousinectious diseases.

Disabling saety controls orguarding on equipment andmachinery.

FAILURE TO COMPLY with health,saety or environmental regula-tions and procedures.

EHS COMPLAINTS rom employees,customers or neighbors.

UNREPORTED environmental,health or saety hazards oraccidents.

FAILING TO RESPOND promptly toconcerns about possible productsaety issues.

MISSED OPPORTUNITIES or reduc-ing waste and toxic materials.

FAILING TO FOLLOW GE POLICIESor the management, shipping,transportation, import/export

and disposal o hazardousmaterials and chemicals.

RISKS AND LIABILITY associatedwith new acquisitions as well asboth new and existing products,processes, services and venturesthat present increased legalliability and reputational risk.

INADEQUATE SECURITY proceduresor practices that may presentsaety threats to a acility and/

or employees.

NEW PRODUCTS, processes,ventures or acquisitions thatpresent increased legal liabilityand reputational risk.



48/64


Security &crisis managementWHAT TO KNOW

In an age o increasing terrorist threats,

protecting the security o our people, workplaces,inormation and businesses is critical. It startswith every business implementing a rigorous andcomprehensive security and crisis management(SCM) plan. GEs SCM plan includes measures

or preventing terrorist and other criminal actscovering our employees, acilities, inormation,inormation technology (IT) inrastructure, businesscontinuity and crisis management. In addition,employees must take every precaution to avoid

doing business with terrorists or those thatsupport terrorist activity.

ANSWER TO QUESTION ON PAGE 43 No, dont ship the equipment until the screening is done.GE cannot agree to do business with a customer, supplier or any other third party until aterall required Watchlist screening has been completed


49/64

47

IntheGEcommunity


IMPLEMENT RIGOROUS PLANS toaddress the security o employ-ees, acilities, inormation, ITassets and business continuity.

PARTICIPATE IN your businesssemergency planning and emer-gency drills.

COMPLY WITH the entry and exit

rules at GE acilities, includingwearing the appropriate badge.

PROTECT ACCESS to GE acilitiesrom all but authorized personnel.

PROTECT IT ASSETS rom thet ormisappropriation.

CREATE AND MAINTAIN a sae work-ing environment this includesidentiying and reporting indica-tors o workplace violence.

COMPLY WITH global immigrationrules when traveling internation-ally, and ensure that employeesor visitors who work or you orare closely associated with your

business also comply.

COMPLY WITH all GE internationaltravel policies. Obtain appropri-ate pre-clearances to designatedcountries.

CONDUCT appropriate back-ground checks on new hiresand contractors, whereverallowed by law.

ENSURE PROPER BUSINESS continu-ity plans are prepared or anemergency.

SCREEN all customers, suppliers,

agents and dealers againstappropriate terrorist Watchlists.

REPORT ANY APPARENT securitylapses to your manager, CrisisManagement Leader or GEOmbudsperson.

WHAT TO DO

INDIvIDUALS AT GE FACILITIES notwearing appropriate badges.

UNSECURE IT ASSETS, such aslaptops, servers, etc.

INADEQUATE PROTECTION ohazardous materials.

UNSECURE AREAS OF A FACILITYwhere only authorized personnelare allowed to enter.

SECURITY COMPLAINTS romemployees, customers orneighbors.

UNAUTHORIzED ENTRY to aacility.

DOING BUSINESS with a customer,supplier or any third party with-out sucient screening.



50/64

ProtectingGE assets

Section Five Intellectual propertyControllership

Conficts o interestInsider trading & stock tipping


51/64

ProtectingGEassets

49

Id like to persuade my customer topurchase a new product beore they

really need it, because it will helpme exceed my quarterly sales goals.I could oer them a discount, and

we could hold the product at ourplant until they need it .

I the customer agrees, can I do this?

SEE PAGE 52:

CONTROLLERSHIP

One o our products will soon have a new eaturethat will really help it outperorm the competition.A big customer o mine is pressing me to describethe new eature to her now, because she needs tomake her buying decisions this week. I know GEwants to patent the eature, but Im not sure theapplication has been led yet.

Can I show the customer the new eature?

SEE PAGE 50:

INTELLECTUAL PROPERTY


52/64


Intellectual propertyWHAT TO KNOW

GEs intellectual property is one o its mostvaluable assets. All employees must work to

saeguard our patents, trademarks, copyrights,trade secrets and other proprietary inormation.At the same time, it is critical that we respectthe valid intellectual property rights o others.Unauthorized use o others intellectual propertycan expose the Company and even individualGE employees to civil law suits and damages,including signicant nes and criminal penalties.A key to protecting our intellectual property and,at the same time, guarding against these risks,is the timely and reasonable review o new

GE products, services, processes and sotware,or possible inventions and trade secrets andinringement o the intellectual property rightso others.

ANSWER TO QUESTION ON PAGE 49 No. Patent counsel should be consulted rst, because showingthe eature to the customer beore a patent application is led could result in the loss o GEs rightto obtain a patent.


53/64

ProtectingGEassets

51


IDENTIFY AND PROTECT GEintellectual property.

FOLLOW THE REQUIREMENTS oGEs Submitted Ideas Procedure(ound at ge.com/en/subidea)in handling any unsolicitedideas rom outsiders as wellas any employee ideas notcovered by the Employee

Innovation and ProprietaryInormation Agreement (EIPIA).For more inormation, consultthe Intellectual PropertyRights Management Procedureound at integrity.ge.com.

RESPECT vALID PATENTS, copy-righted materials and otherprotected intellectual propertyo others.

CONSULT with Company legalcounsel concerning necessarylicenses or approvals to useprotected intellectual propertyo others such as patents,trademarks or proprietary inor-mation (i.e. inormation that isin condence and not publiclyknown or generally available).

CONSULT with company legalcounsel beore:

Soliciting, accepting or usingproprietary inormation ooutsiders (or example,soliciting rom a customerproprietary inormation oa competitor).

Disclosing GE proprietaryinormation to outsiders.

Permitting outsiders touse GE intellectual property.

UNDERSTAND YOUR RESPONSIBILITIESto the Company regarding newinventions, ideas that you maydevelop as a GE employee andthe Companys inormation.Consult with company legalcounsel i you have any ques-tion about these responsibilities,or about the EIPIA (signed byexempt employees and other

employees in a position o trustor likely to make inventions).

COMPLY with the guidelines oruse o the GE primary trade-marks and trade names (avail-able at gebrandcentral.com)and GEs Intellectual PropertyRights Management Procedureound at integrity.ge.com.

WHAT TO DO

ACCEPTING PROPRIETARY INFORMA-

TION belonging to an outsider,without rst consulting companylegal counsel.

DISCUSSING GE PROPRIETARY IN-FORMATION with customers orsuppliers.

USING ANOTHER COMPANY to de-velop new products or sotwarewithout a written agreement inplace covering ownership andother rights in the developedintellectual property.

PASSING ON, or technical or man-agement review, an outsiderssuggestion or a new product,product eature, service or name,

without ollowing the GESubmitted Ideas Procedure(ound at ge.com/en/subidea).

INTRODUCING, OR PROvIDING

INFORMATION about, a newproduct or service beore patentapplications have been led ora decision has been made notto le an application.

INTRODUCING A NEW PRODUCTor service, or new product orservice name, beore checkingor patent or trademarkinringement.

THREATENING anyone suspectedo inringing any GE intellectualproperty without rst consultingwith company legal counsel.

EMPLOYING A NEW PERSON, espe-cially a person who previouslyworked or a competitor, with-out putting in place saeguardsto prevent the person rom in-advertently disclosing or usingthe proprietary inormation othe previous employer.

EMPLOYING A PERSON who has notsigned the EIPIA in a job where

inventions are likely to be made.



54/64


ControllershipWHAT TO KNOW

Controllership embodies three undamentalelements: (1) rules that classiy transactions and

balances appropriately; (2) systems and controlsthat protect assets and accumulate inormationconsistently and correctly; and (3) nancial andtransaction reporting that is timely and unbiased.Controllership creates the right environment ordisclosing timely, reliable and accurate inormationto government agencies and the public.

ANSWER TO QUESTION ON PAGE 49 No. This can be damaging both economically (giving away margin andputting strain on a customer relationship) and rom an accounting standpoint (not technically a sale,as the rules or revenue recognition have not been met).


55/64

ProtectingGEassets

53


FOLLOW GES GENERAL

ACCOUNTING PROCEDURES, aswell as applicable generallyaccepted accounting principles,standards and regulationsor accounting and nancialreporting.

ENSURE THAT FINANCIAL AND NON-

FINANCIAL INFORMATION and

operating metrics are reportedaccurately and in a timelyashion.

MAINTAIN COMPLETE, ACCURATE

AND TIMELY records and accountsto appropriately refect all busi-ness transactions.

SAFEGUARD ALL COMPANY ASSETS(physical, nancial andinormational).

PROvIDE TIMELY, CANDID FORE-

CASTS and assessments.

MAINTAIN SOUND PROCESSES andcontrols.

COMPLY WITH GES DOCUMENT

MANAGEMENT PROCEDURES (oundat integrity.ge.com) as well asall applicable laws and regula-tions relating to the preserva-tion o documents and records.

PRESERvE DOCUMENTS AND RE-

CORDS relevant to pending orreasonably oreseeable litiga-

tion, audits or investigations,and as directed by Companycounsel.

WHAT TO DO

FINANCIAL RESULTS THAT SEEM

INCONSISTENT with underlyingperormance.

INACCURATE FINANCIAL RECORDS,such as overstated travel andliving expense reports, or erro-neous timesheets or invoices.

TRANSACTIONS THAT ARE

INCONSISTENT with good businesseconomics.

ABSENCE OF CONTROLS to protectassets rom risk o loss.

PHYSICAL ASSETS or other re-sources that could be more ullyused, reallocated or disposed o.

CIRCUMvENTING REvIEW andapproval procedures.

INADEQUATE ROUTINES AND

CONTROLS at newly acquiredbusinesses and at remote and/or understaed sites.

INADEQUATE ROUTINES AND

CONTROLS to preserve documents(including e-mail) or pending or

reasonably oreseeable litigation,audits and investigations.

DISPOSAL OF DOCUMENTS withoutknowing what is being discardedor whether the documents aresubject to legal preservationrequirements.

FALSE OR ExAGGERATED STATEMENTSin e-mail, presentations or otherdocuments.



56/64


I was chatting with my brother andmentioned that I had an upcomingbusiness trip to close the deal orGE to acquire Company X.

Could this create a problem?

SEE PAGE 58:

INSIDER TRADING & STOCK TIPPING


57/64

ProtectingGEassets

55

Your cousin owns a companythat supplies raw materials to

a GE business.

Is that a prohibited conficto interest, no matter whatGE business youre in?

SEE PAGE 56:

CONFLICTS OF INTEREST


58/64


Conficts o interestWHAT TO KNOW

On the job or in your ree time, nothing you doshould confict with your responsibilities to GE.

No activity at work or at home should hurt GEsreputation or good name. Misusing GE resourcesor infuence is also prohibited. Even when nothingwrong is intended, the appearance o a confictcan have negative eects. It is crucial to considerhow your actions might appear, and to avoid theperception o a confict o interest.

ANSWER TO QUESTION ON PAGE 55 This is not explicitly prohibited, but the Conficts o Interest policyrequires that you disclose the situation to GE management, and that you not attempt to infuenceGE business with your cousins company.


59/64

ProtectingGEassets

57


DISCLOSE (in writing to yourmanager and to company legalcounsel) all o your outsideactivities, nancial interests orrelationships that may eitherpresent a confict or the appear-ance o one.

USE GOOD JUDGMENT in all per-sonal and business dealings

outside your GE job.

AvOID ACTIONS OR RELATIONSHIPSthat may cause potential con-ficts or create the appearanceo a confict with your job orGEs interests.

DO NOT MISUSE or use or per-sonal gain GE resources, intel-lectual property, time oracilities this includes oceequipment, e-mail and com-puter applications.

DO NOT TAKE or yoursel person-ally any opportunities that GEcould have an interest in that

are discovered through the useo GE position, inormation orproperty.

GET APPROvALS beore acceptingocer or director positions withan outside business while youare a GE employee.

GET YOUR MANAGERS APPROvALwhen accepting not-or-protboard positions, particularlyi the organization has a GErelationship or might expect

GE nancial or other support.

WHAT TO DO

FINANCIAL INTERESTS in a com-pany where you could personallyaect GEs business with thatcompany (or example, a cus-tomer, supplier or investment).

PART-TIME JOBS which youperorm using GE hours or GEequipment or materials.

GIFTS o other than nominal

value rom suppliers, customersor competitors, particularly iyoure making decisions (on GEsbehal) that involve them.

PERSONAL DISCOUNTS or otherbenets rom suppliers, serviceproviders or customers that thepublic or your GE peers do notreceive.

DIRECTING BUSINESS to supplierswhen you know they are ownedor managed by your amily mem-bers or close riends.

MISUSING GE RESOURCES, yourposition or infuence to promoteor assist an outside activity.

HIRING, PROMOTING OR DIRECTLYSUPERvISING a amily member orclose riend.

PERSONAL RELATIONSHIPS thatmay confict with your GEresponsibilities or compromisecompany interests.



60/64


Insider trading& stock tippingWHAT TO KNOW

In the course o your job, you may learn o

material inormation about GE or other companiesbeore it is made public. You may simply overheara hallway conversation or come across a memolet at a copy machine. Using this inormationor your nancial or other personal benet or

conveying this inormation to others constitutesa violation o this policy and may even violate thelaw. This includes buying or selling the securitieso any company about which you have materialnon-public inormation and giving this inside

inormation to anyone else who might basenancial trades on the inormation youve shared.

ANSWER TO QUESTION ON PAGE 54 Yes, i Company X is a public company and the possible acquisitiono Company X has not been publicly announced. I your brother trades Company X stock based onyour tip, both o you could be charged with insider trading.


61/64

ProtectingGEassets

59


DO NOT BUY OR SELL the securitieso any company, including GE,either directly or through amilymembers or other persons orentities, while you are awareo inside inormation about thecompany. (This is known asinsider trading.)

DO NOT RECOMMEND OR SUGGEST

that anyone else buy or sellthe securities o any company,including GE, while you haveinside inormation about thecompany. (This is known astipping.)

MAINTAIN THE CONFIDENTIALITYo Company inormation anddo not convey inormation toanyone outside the Companyunless it is necessary or theCompanys business activities.

IF THE NATURE OF YOUR BUSINESSS

ACTIvITIES and your position inthe business subject you to

additional requirements relatingto buying and selling securities(such as pre-clearing personaltrades through the TransactionControl Authority, ound atintegrity.ge.com), learn andollow all o those requirements.

IF QUESTIONS ARISE, consultcompany counsel beore trad-ing in the security or disclosingcompany inormation.

WHAT TO DO

NON-PUBLIC INFORMATION WHICH,IF DISCLOSED, would reasonablybe expected to aect the priceo a security or would infuenceyour decision to buy, sell or holda security, such as an earningsannouncement or a prospectiveacquisition announcement (thisis known as inside inormation).

BUYING OR SELLING A SECURITYbecause you hear or learn oinormation at work that youthink will make the price goup or down once its publiclyannounced.

ENGAGING IN TRADING ACTIvITYaround the time o a signicantcompany announcement.

DISCUSSING GE BUSINESS withamily and riends.

TALKING ABOUT WHAT YOURE

WORKING ON or where youregoing on company business orwho visited the oce.



62/64


IndexA

Acquisition 21, 36, 37, 45, 58, 59Aliates 5, 61Armative action 41Agent 5, 19, 25, 27, 37, 47Antitrust laws 36Appendix 61Assets 13, 19, 47, 48, 50, 52, 53

B

Board o directors 9, 37

Boycotts 25Bribery 18, 19, 26Business policies and procedures 12, 37

C

Cash transactions 27Code o conduct 1, 2, 3Commission 19Competing globally 13, 3437Competition laws, complying with 3437Competitors 33, 35, 36, 37, 51, 57Compliance specialists 4, 6, 9, 27Concerns, Integrity 1, 4, 6, 7, 810, 11, 41, 45Condential Inormation 8, 21, 59

Condentiality 8, 21, 59Conficts o interest 3, 21, 48, 55, 5657Conficts between laws 41, 61Consultants 5, 19, 33Contractors 5, 19, 47Contracting ocer 33Contributions 19Controlled aliates 5, 61Controllership 48, 49, 5253Copyrights 50, 51Cost-charging 33Crisis Management 38, 43, 4647Customer relationships 26, 52

D

Disability 41Discrimination 40Distributors 5, 19, 33Due diligence 19, 26

E

Embargoed countries 25Employee responsibilities 1, 6, 12, 32, 50,

51, 56, 57Employment Practices 3, 11, 33, 38, 39,

4041Entertainment 18, 19Environment 3, 20Environment , health & saety 20, 21, 38, 43,

4445Ethical conduct 1, 2, 3, 7Ethical standards 32Exports 23, 24, 25, 45

F

Fair employment practices 3, 38, 39, 4041Facilitating payment 19Family 19, 33, 57, 59Financial records 53Financial reporting 52, 53

Forecasts 53Fund transers 23, 26, 27

G

Generally accepted accountingprinciples 53

Gits 18, 19, 21, 57Government business 13, 3033Government contracts 21, 33Gratuity 19, 33

H

Harassment 41Hazardous materials 45, 47Health 20, 21, 38, 43, 44, 45Hiring 33, 41, 57Hostile work environment 41

I

Imports 23, 25, 45Improper payments 16, 17, 1819In the GE community 13, 3847Independent contractors 5, 19, 47Inside inormation 58, 59Insider trading & stock tipping 48, 54, 5859Integrity Web site 4, 6, 9, 21, 25, 41, 51, 53,

59, 62Intellectual property 48, 49, 5051, 57International Trade Controls (ITC) 16, 22,

2425

J

Joint venture 37

K

Know Your Customer 25, 26, 27Know Your Supplier 24, 25

L

Laundering money 16, 23, 26, 27Leadership responsibilities 1, 3, 7, 11Licenses 51Licensing agreements 37

M

Merger 36, 37Minorities 21, 41Money laundering prevention 16, 23, 2627

N

Non-controlled aliates 5Non-public inormation 58, 59Not-or-prot 57

O

Ombudsperson 1, 4, 6, 7, 9, 47Outside activities 57

PPart-time job 57Patents 49, 50, 51Payments 16, 17, 1819, 25, 26, 27, 31Penalties or violations 11Personal data 20, 28, 29, 41Political contributions 19Price 17, 25, 37, 59Privacy 16, 21, 22, 2829, 40, 41Property, company 41

Property, intellectual 48, 49, 5051, 57Proprietary inormation 21, 41, 50, 51Protecting GE assets 13, 4859

R

Raising a concern 6, 810, 11Red fags 25, 26Regulatory 14, 15Relatives 21Responsibilities, employee 1, 6, 12, 32, 50,

51, 56, 57

Responsibilities, leader 1, 3, 7, 11Restrictive trade practice 25Retaliation 7, 8, 11

S

Saety 21, 38, 43, 44, 45Sales representatives 5, 19, 33Securities 58, 59Security and crisis management 29, 38, 43,

45, 4647Sexual advances 41Stock tipping 48, 54, 5859Submitted Ideas Procedure 51Subsidiaries 5, 61

Supplier relationships 16, 17, 2021Supplier Reputational Guidelines 21Suppliers 13, 16, 17, 2021, 22, 24, 25, 29,

33, 37, 46, 47, 51, 57Suspicious transactions 23, 26, 27

T

Terrorism 2627, 4647Third parties 5, 7, 19, 26, 27, 29, 37, 46, 47Toxic materials 45Trademarks 50, 51Trade names 51Trade secrets 50Transaction Control Authority 59Transactions 19, 25, 26, 27, 28, 32, 33, 35,

52, 53Travel and living expenses 18, 19, 53

v

Veterans 21, 41Violations 4, 6, 7, 8, 11, 12, 29, 41, 58

W

Watchlists 25, 43, 4647Web site 4, 6, 9, 62Working with customers & suppliers 13,

1629Working with governments 30, 31, 3233Women 21, 41

YYour personal commitment 1, 4


63/64

AppendixWhich LaW appLiES

GE conducts business in more than 100 countries around the world. Our employees arecitizens o many dierent countries. As a result, our operations are subject to the lawso many countries, provinces, states and municipalities, and organizations such as theEuropean Union.

An important challenge or all o us is to understand how these laws may apply to ouroperations. GE, the parent company, is a corporation organized in the United States.The laws o the United States requently extend to the operations o GE and its aliatesthroughout the world, as well as to the business activities o GE employees wherever theylive and work. Other countries may also apply their own laws outside o their borders totheir own citizens and to corporations that are organized under their laws, such as GEsubsidiaries or other controlled aliates.

The reerences in GE policies to the laws o the United States and the other countries wherewe do business refect the reality that a global company is regulated by many dierent lawsat the same time. In some instances, there may be a confict between the applicable laws

o two or more countries. When you encounter such a confict, it is especially important toconsult company legal counsel to understand how to resolve that confict properly.

2008 General Electric Company Printed in the U.S.A.

The cover to this document was printed on paper made with 30% postconsumer waste ber. The paper was

manuactured using wind-generated energy and is Green Seal certied. The inside pages to this document were

printed on paper containing 10% postconsumer recovered ber and manuactured with green power in the orm

o electricity generated rom renewable resources including 85% Hydro Power, 10% Wind Power and 5% Biogas.

GE employed a printer that produces all o its own electricity and is a certied totally enclosed acility that

produces virtually no volatile organic compound emissions.


64/64

General Electric Company

Faireld, Connecticut 06828

Visit the integrityWeb sitetegty.ge.GE tet: elyees ly

Yll f e t lg:

Complete policies, including questions and answers

Procedures and guidelines

How to raise a concern

How to contact an expert

Business integrity Web sites

Compliance training

Tools and resources

GE Spirit Letter R10822

Documents

Transcript of GE Spirit Letter R10822